How To Develop Your Skill For Great Success And Happiness Including Become CPA? | Additional special tips From Admin
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Chartering vessel to decommission oil and gas wells is ECI
The Tax Court held that a U.K. limited liability company’s charter income from decommissioning oil and gas wells and removing debris on the U.S. outer continental shelf (OCS) was effectively connected income (ECI) and subject to U.S. income tax based on Sec. 638 and the U.S.—U.K. tax treaty.
Facts: Oil and gas companies that work on mining activities in the Gulf of Mexico are subject to decommissioning requirements by the U.S. Department of the Interior. These obligations include the removal of all mining structures, including excavating around damaged rigs, severing metal components from toppled platforms, plugging abandoned wells, and removing metal debris from the seabed upon the termination of each lease.
In 2009, EPIC Diving & Marine Services LLC (EPIC) won a bid to decommission oil and gas wells in the Gulf of Mexico on the OCS. The OCS is all submerged land, subsoil, and seabed that belongs to the United States. In the Gulf of Mexico, the OCS extends up to 200 nautical miles from the U.S. coastline. Because EPIC did not have the proper marine vessel to do the job, it leased the M.V. Adams Challenge (Challenge Vessel) with its crew from Adams Challenge Ltd. (Adams Challenge), a U.K. company. Adams Challenge consisted solely of the Challenge Vessel, which was its only income–producing asset. The Challenge Vessel was equipped with state–of–the–art specialized systems to decommission the oil and gas wells in the Gulf of Mexico. EPIC used the Challenge Vessel from 2009 to 2011 on 11 decommissioning projects.
Issues: Adams Challenge did not file U.S. federal tax returns for 2009 and 2010 and filed a delinquent 2011 Form 1120–F, U.S. Income Tax Return of a Foreign Corporation, in 2013, in which it reported ECI of $2,736,450 and taxable income of $369,821. In 2014, the IRS sent Adams Challenge a notice of deficiency for tax years 2009—2011. For 2009, the IRS determined that Adams Challenge had ECI of $13,595,167, and for 2010, in an amended pleading, the IRS determined that the company’s ECI was $21,380,541. For 2011, the IRS concluded that Adams Challenge had underreported ECI by $9,897,975.
Sec. 7701(a)(9) defines the United States as “only the States and the District of Columbia.” However, Sec. 638, added in 1969, expands the definition of the United States to include the OCS but only “with respect to mines, oil and gas wells, and other natural deposits.” Regs. Sec. 1.638–1(c)(4) further specifies that “[p]ersons, property, or activities are within the United States … only to the extent such persons, property, or activities are engaged in or related to the exploration for, or the exploitation of, mines, oil and gas wells, or other natural deposits.”
Adams Challenge gave seven arguments for the Tax Court to examine. The first three arguments related to Sec. 638. Adams Challenge argued that:
The next four arguments looked to the U.S.—U.K. income tax treaty, especially Article 21, “Offshore Exploration and Exploitation Activities.” Adams Challenge argued that:
Holding: The Tax Court rejected all of Adams Challenge’s arguments and contentions, holding that:
— By Richard Seo, CPA, and David R. Silversmith, CPA, CFP, CFE, partner and tax manager, respectively, at Crowe LLP in New York.
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A note for you if you pursue CPA licence, KEEP PRACTICE with the MANY WONDER HELPS I showed you. Make sure to check your works after solving simulations. If a Cashflow statement or your consolidation statement is balanced, you know you pass right after sitting for the exams. I hope my information are great and helpful. Implement them. They worked for me. Hey.... turn gray hair to black also guys. Do not forget HEALTH?
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